News & Analysis as of

Disclosure Requirements Mortgages Consumer Financial Protection Bureau (CFPB)

Orrick, Herrington & Sutcliffe LLP

CFPB: TILA does not preempt state laws on commercial financial disclosure

On March 28, the CFPB issued a determination that state disclosure laws covering lending to businesses in California, New York, Utah, and Virginia are not preempted by TILA. ...more

Bradley Arant Boult Cummings LLP

CFPB Releases TRID Guidance for Juneteenth National Independence Day

Late last week, the Consumer Financial Protection Bureau (CFPB) released an interpretive rule that provided much-welcome guidance related to the effect of the new Juneteenth National Independence Day on disclosure waiting...more

Troutman Pepper

CFPB Issues Interpretive Rule on Juneteenth and Mortgage Disclosure Requirements

Troutman Pepper on

On June 17, the president signed legislation designating “Juneteenth National Independence Day, June 19” as a federal holiday. Because the legislation took effect immediately, it raised compliance questions for residential...more

Goodwin

CFPB To Revisit Trump-Era QM Final Rules

Goodwin on

In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more

Ballard Spahr LLP

CFPB Announces Availability of Beta HMDA Filing Platform for 2021 Data

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Although HMDA reporting institutions are busily working on their submission of 2020 data, the CFPB recently announced the availability of a beta version of the HMDA reporting platform for 2021 data. (As previously reported,...more

Goodwin

CFPB, FTC And 50 States Show Power In Numbers With Operation Corrupt Collector

Goodwin on

In the News. The Consumer Financial Protection Bureau (CFPB), along with the Federal Trade Commission (FTC) and more than 50 federal and state law enforcement partners, announced Operation Corrupt Collector, a nationwide law...more

Ballard Spahr LLP

FFIEC Announces Release of 2019 HMDA Data

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On June 24, 2020, the Federal Financial Institutions Examination Council (FFIEC) announced the release of the 2019 Home Mortgage Disclosure Act (HMDA) data. ...more

Ballard Spahr LLP

CFPB Publishes TRID FAQ’s and a Factsheet on Treatment of Title Insurance Premiums

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On June 9, 2020, the CFPB published four new TRID FAQ’s and a TRID Factsheet (“Factsheet”). While the Factsheet is focused solely on the handling of title insurance disclosures under the rule, the FAQ’s cover various topics,...more

Ballard Spahr LLP

CFPB Updates HMDA FAQs

Ballard Spahr LLP on

The CFPB recently updated its Home Mortgage Disclosure Act (HMDA) FAQs, regarding the reporting of race, ethnicity and sex for applications taken by mail, internet or telephone. ...more

Ballard Spahr LLP

CFPB Publishes TRID FAQ’s on Treatment of Lender Credits

Ballard Spahr LLP on

The CFPB recently published ten new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more

Ballard Spahr LLP

CFPB to Assess TRID Rule’s Effectiveness

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The Dodd-Frank Act requires the CFPB to conduct an assessment of each “significant rule” adopted by the Bureau. The Bureau has determined that the TILA/RESPA Integrated Disclosure (TRID) Rule qualifies as a “significant...more

Ballard Spahr LLP

CFPB Updates TRID Rule FAQs to Address Providing a Loan Estimate to Consumers

Ballard Spahr LLP on

The CFPB recently updated the TRID rule FAQs to address questions about providing a Loan Estimate to consumers. The FAQs mostly confirm guidance previously provided by the CFPB in various forms. ...more

ArentFox Schiff

Self-Reporting, TRID, and CFPB

ArentFox Schiff on

On July 11, 2019, I presented at the American Bankers Association webinar, entitled, “Mortgage Disclosure Cures and Corrections — Mitigating Liability.” Below is a summary of the points presented in the webinar and additional...more

Ballard Spahr LLP

CFPB Releases 2018 HMDA Data

Ballard Spahr LLP on

The CFPB recently released modified Home Mortgage Disclosure Act (HMDA) loan application registers of approximately 5,400 financial institutions for calendar year 2018. ...more

Ballard Spahr LLP

CFPB Revises TRID Guides to Reflect Black Hole Fix

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The CFPB recently issued revised TILA/RESPA Integrated Disclosure (TRID) rule guides to reflect the adoption of an amendment to the rule to fix the so-called “black hole” issue.  ...more

Bricker Graydon LLP

Mortgage lenders: The “black hole” has closed

Bricker Graydon LLP on

In astronomy, there can be no escape from a black hole. In the world of residential mortgage lending, the CFPB has charted a new course, finally creating an escape from one of TILA/RESPA’s most impracticable rules. On April...more

Ballard Spahr LLP

CFPB Finalizes Black Hole Fix under TRID Rule

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The CFPB, which is now referring to itself as the “Bureau of Consumer Financial Protection,” published the long-awaited final rule to address the so-called “black hole” issue under the TILA/RESPA Integrated Disclosure (TRID)...more

Ballard Spahr LLP

CFPB Finalizes Black Hole Fix under TRID Rule

Ballard Spahr LLP on

The Consumer Financial Protection Bureau (CFPB) published the long-awaited final rule to address the so-called "black hole" issue under the TILA/RESPA Integrated Disclosure (TRID) rule. ...more

Kilpatrick

CFPB Finalizes Amendment to TRID Mortgage Disclosure Rule

Kilpatrick on

Amendment Addresses the “Black Hole” Issue - On April 26, 2018, the Consumer Financial Protection Bureau (CFPB or Bureau) finalized an amendment to its TILA-RESPA Integrated Disclosure (TRID) Rule that addresses when...more

Ballard Spahr LLP

House Passes Bill to Amend TRID Rule Disclosures

Ballard Spahr LLP on

On February 14, 2018, the United States House of Representatives passed the TRID Improvement Act of 2017, H.R. 3978, by a vote of 245 to 171. The bill would amend the manner in which title insurance premiums are disclosed...more

McGuireWoods LLP

CFPB Announces Intent to Reconsider Disclosure Rule

McGuireWoods LLP on

On December 21, 2017, the Consumer Financial Protection Bureau (CFPB) issued a public statement regarding implementation of the Home Mortgage Disclosure Act (HMDA), noting that it plans to reconsider aspects of the mortgage...more

Ballard Spahr LLP

CFPB Launches Beta Version of HMDA Platform

Ballard Spahr LLP on

On Friday November 3, 2017 the Consumer Financial Protection Bureau (CFPB) announced the launch of the Internet-based platform that financial institutions will use to submit data under the Home Mortgage Disclosure Act (HMDA)....more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

SEC Proposes Rules to Implement FAST Act Mandate to Modernize and Simplify Disclosure - On October 11, 2017, the Securities and Exchange Commission (SEC) proposed amendments "to modernize and simplify disclosure...more

Ballard Spahr LLP

CFPB updates TRID Rule small entity compliance guide

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The CFPB recently released a revised version of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide. The revised version incorporates the recent amendments to the rule that became effective on October...more

Ballard Spahr LLP

House Financial Services Committee schedules Oct. 11 mark-up of “Madden fix” bill

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Among the more than 20 bills that the House Financial Services Committee is scheduled to mark-up this Wednesday, October 11, is a bill to provide a “Madden fix” as well as several others relevant to consumer financial...more

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